A bill to amend the Internal Revenue Code of 1986 to prevent the continued use of renouncing United States citizenship as a device for avoiding United States taxes.
Read twice and referred to the Committee on Finance.
Congressional Research Service
Official summary
Version 00 · Introduced in Senate · Jan 30, 2003
Amends the Internal Revenue Code to establish that all property of "covered expatriates" shall be treated as sold on the day before the "expatriation date" for its fair market value, and that gain and loss shall be taken into account for the taxable year of the sale (with proper subsequent adjustment). Defines "expatriate" and "expatriation date."Permits an individual to make an irrevocable decision to defer the additional tax attributable to such property provided that adequate security is furnished and that the individual waives any rights under treaties of the United States that would preclude assessment or collection of relevant tax.Excludes certain "United States real property interests" and interest in certain retirement plans from counting as sold under this Act. Establishes special rules applicable to "covered expatriates'" interests in trusts and qualified trusts, including a tax in instances of the latter. Sets forth that such tax shall be replaced by another tax under certain delineated conditions, including if a trust ceases to be a qualified trust.Imposes a tax on "covered gifts and bequests" of more than $10,000 from expatriates to American citizens and residents, with certain specified exceptions.
No related bills are listed in this snapshot. This does not establish whether the proposal has appeared in earlier Congresses.
Source last updated: Apr 7, 2025. Consult Congress.gov for the current record.
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